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Data policy


Staines Hockey Club – Photography & Filming Policy
Last reviewed: 6 September 2026

1. Who This Policy Applies To
This policy applies to:

  • All children and young people involved with Staines Hockey Club (anyone under 18)
  • All parents and carers responsible for a child involved with the Club
  • All staff, volunteers, coaches, team administrators, and committee members
  • All spectators attending Club activities, matches, training, tournaments, or events

2. Our Commitment
Staines Hockey Club is committed to keeping children and young people safe.
Photography and filming can celebrate achievements and promote our Club, but must always be carried out responsibly, respectfully, and in line with safeguarding and data protection requirements.

3. Data Protection and Consent
Identifiable photos and videos of children are personal data under the UK GDPR and the Data Protection Act 2018.

Lawful basis
Our lawful basis for taking and using identifiable images of children is consent (UK GDPR Article 6(1)(a)).
Where images may reveal special category data (e.g., disability‑related adjustments), our lawful basis is explicit consent (Article 9(2)(a)).

How consent is collected
Consent is collected through the Pitchero consent form when a member is registered or updated on the platform.

How consent is stored
Consent records are stored securely within Pitchero and Hockey Club records, including:

  • the consent given
  • the exact wording shown at the time consent was provided
  • any updates or withdrawals of consent

Link to our main Privacy Policy
This policy should be read alongside the Staines Hockey Club Privacy Policy, which explains:

  • your data protection rights
  • how long images are retained
  • how to withdraw consent
  • how to contact us or the ICO

4. What We Will Do
We will:

  1. Take, store, and process images and videos in accordance with UK GDPR and safeguarding best practice
  2. Promote safe and respectful use of images
  3. Ensure robust procedures are in place for photography and filming
  4. Gain written consent from parents/carers and (where appropriate) children before taking or sharing photos or videos
  5. Allow consent to be withdrawn at any time
  6. Use images only in accordance with the consent provided
  7. Explain how images will be used and stored when requesting consent
  8. Put practical measures in place to ensure children without consent are not photographed
  9. Use images and videos only for training, promoting, and celebrating our Club
  10. Store images securely and restrict access to authorised individuals
  11. Allow only authorised staff/volunteers who have received appropriate training to take photos or videos
  12. Monitor and manage the use of images to prevent misuse
  13. Encourage reporting of any concerns to staff or the safeguarding officer
  14. Act immediately on any concerns raised
  15. Provide training to staff and volunteers
  16. Use external photographers or videographers only if they agree to follow this policy
  17. Follow our Social Media Policy when sharing images online

5. What We Will Not Do
We will not:

  1. Take or use photos or videos that are inappropriate, intrusive, or abusive
  2. Include full names, addresses, or other identifying details alongside images of children
  3. Use images that make a child easily identifiable (e.g., close‑ups with name labels, school logos, or unique identifiers)
  4. Share images with third parties unless consent has been given

6. Storage, Access, and Retention
Images will be stored securely and access will be limited to authorised individuals.

Retention period
In line with our Privacy Policy:

  • Photos may be retained indefinitely as part of the Club archive unless consent is withdrawn.
  • If consent is withdrawn, images will no longer be used and will be deleted where reasonably possible.

Consent record‑keeping
Consent records are retained within Pitchero and in Hockey Club records in line with our data retention schedule.

7. Managing Opt‑Outs
If a child does not have consent for photography or filming, we will:

  • Maintain an up‑to‑date list of children without consent
  • Inform coaches, team administrators, and relevant volunteers
  • Put practical measures in place at events (e.g., wristbands, seating arrangements, or exclusion zones)
  • Ensure group photos do not include children without consent
  • Check images before publication

8. Photography at Public Events
Some Club activities take place in public spaces (e.g., tournaments, league fixtures, open days).
Where photography may occur in public areas:

  • We will display notices where reasonably possible
  • We will ensure children without consent are not photographed
  • We will remind spectators of appropriate behaviour and safeguarding expectations

9. Photography by Parents and Spectators
Parents and spectators may take photos or videos at matches and events for personal use only, provided they:

  • Do not take intrusive or inappropriate images
  • Do not share images of other children online without consent
  • Follow instructions from Club officials if photography needs to be restricted for safeguarding reasons
  • Respect any child who does not have photography consent

If concerns arise, Club officials may ask individuals to stop photographing.

10. Livestreaming
The Club may livestream matches or events for training or promotional purposes.

Livestreaming will only occur when:

  • consent has been obtained through Pitchero
  • children without consent are excluded from the filmed area
  • the livestream is monitored by authorised staff
  • no identifying information is displayed
  • the stream is hosted on a secure platform
  • recordings are stored and used in line with this policy and our Privacy Policy

11. External Photographers and Videographers
External individuals or organisations may only take photos or videos if they:

  • Sign an agreement confirming they will follow this policy
  • Use images only for the agreed purpose
  • Store images securely
  • Delete images once the agreed purpose is complete

12. Monitoring and Review
This policy will be reviewed every three years, or sooner if:

  • legislation changes
  • England Hockey updates its guidance
  • safeguarding case reviews require changes
  • significant events indicate a need for revision

13. Safeguarding Contacts
In an emergency where a child is at immediate risk, call 999.

NSPCC Helpline: 0808 800 5000
Childline: 0800 1111